Presented for: 3rd Annual FTA Drug and Alcohol National

Conference

April 30 – May 1, 2008

Presented By: Robbie Sarles

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2000 – National Transit Safety Board (NTSB) issued a directive to the Federal Transit Administration (FTA)• Educate transit systems on potential safety risks

associated with the use of prescription and over-the-counter medication use by employees who perform safety-sensitive duties

• Create reporting mechanism• Incorporate medical review• Train employees

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2000 – FTA issued a “Dear Colleague” letter to all grant recipients• Establish prescription and over-the-counter drug

policy• Institute educational programs that address the

potential dangers of prescription and over-the-counter drug use

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2001 – NTSB called for nationwide changes in how transit agencies monitor employees’ medical and drug-related problems• Increased pressure following MTA accidents

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2002 – FTA responds• Dedicated page of newsletter to prescription and over-the-

counter medication use awareness• Incorporated discussion in FTA-sponsored/supported

workshops and conferences• Conducted survey of transit agencies on prescription and

over-the-counter policies and procedures• Created toolkit of sample policies, procedures, and training

materials• Investigated procedures used by other modes

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2003 – New York City ferry boat accident• Pilot of ferry was under the influence of prescription

painkillers (Tramadol) and diphenhydramine as found in over-the-counter allergy remedies

• Known side effects include drowsiness, dizziness, and confusion

• NTSB determines probable cause of accident was pilot’s “unexplained” incapacitation and failure of New York City DOT to implement and oversee safe, effective operating procedures

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2006 – Prescription and over-the-counter medications listed in top ten contributing factors in truck accidents• Large truck crash causation study assessed 1,000 factors• Prescription medications ranked third of the most commonly-

cited factors in major truck crashes (cited in 26.3% of major crashes)

• Over-the-counter medications ranked eighth, cited in 17.3% of major truck crashes

• Prescription medication was the number one cause in driver-related factors

• Over-the-counter medication ranked fourth among driver-related factors

• Illegal drug use and alcohol use did not make the top twenty

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Published employer prescription and over-the-counter medication policy guidelines

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Purpose of Policy• Acknowledges risks associated with Rx/OTC use• Emphasizes safety• Balances the treatment of medical conditions and the

requirements of performing safety-sensitive job duties• Not intended to force employees in need of medical

attention to work or keep employees who are eligible to work off duty for receiving treatment of a medical condition

Define processes and procedures that implement the policy, such as:• Medical review/authorization• Reporting• Use of leave benefits; limitations

Define Consequences of Violating Specific Policy Provisions• Use of Rx/OTC that contribute to cause or increase the

severity of an accident• Failure to report use• Failure to obtain medical authorization• Other policy provision violations

Ensure that the policy emphasizes and maintains confidentiality• Records• Interaction with medical practitioner

Defined Roles and Responsibilities• Employees• Management/Supervisors• Medical Practitioner (Physician, Dentist, Physician’s

Assistant, Optometrist, Chiropractor, Other)• Pharmacist• Employer MRO/Physician

Provided guidance and understanding on reading and understanding over-the-counter medication labels

Published safety-sensitive employee guidelines for use of prescription and over-the-counter medication

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Be cautious – all Rx/OTC have the potential to be dangerous

Inform your medical practitioner• Sensitive duties performed• Other Rx/OTC/dietary supplements taken• Provide complete medical history

Solicit information from your pharmacy Read warning labels Do not over-medicate Cite the strength/dosage of the prescription

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Never take anyone else’s medication Always monitor your reaction Avoid Rx/OTC that have caused problems in the past Ask for alternative treatments or dosage schedule

DO NOT perform safety-sensitive duties while impaired!

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Provided guidance on documenting prescription and over-the-counter medication involvement in accidents

Guidance on developing an effective employee awareness training program

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Introduction• Purpose of Rx/OTC policy

o Balance treatment of medical condition with safe performance of job duties

• Applicability – Safety-sensitive employees or all employees• Employee responsibility for treatment and safe performance

of duties

Training Elements• An overview of your system’s Rx/OTC policy• An overview of your system’s procedures

o Medical authorizationo Notification/reportingo Forms if applicable

• Consequences of policy violations• Leave policy

o Sick leave/paid time off o Limitations on use

Training Elements• Risks associated with Rx/OTC use• Definition of Rx and OTC• How to read a label• How to read Rx information sheets • Side effects of concern• Common sense rules for taking medication

Published sources of training materials

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US Food and Drug Administration• www.fda.gov

Consumer Healthcare Products Association• www.chpa-info.org

Center for Drug Evaluation and Research• www.fda.gov/cder

National Council on Patient Information and Education• www.bemedwise.org

Agency for Healthcare Research and Quality• www.ahrq.gov

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Provided list of steps to evaluate the risks and benefits of a prescription medication

Model transit Rx/OTC approach

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Medical Authorization• Employee obtains medical authorization form from

employer• Employee asks about side effects and potential impact on

ability to perform dutieso If no adverse impacts – Medical practitioner signs release

indicating employee may perform dutyo If adverse impacts – Medical practitioner signs indicating

employee must be off of duty for a specified amount of time

• Employer may or may not keep form for documentation

Medical Authorization (cont’d)• Form may be reviewed by the employer’s Physician/MRO

o After discussing with prescribing physician, may overturn authorization.

Published alerts• Antihistamines• Dietary supplements• Ritalin• Combining over-the-counter medications• Obtaining prescription and over-the-counter medications

online• Misuse and abuse of prescription and over-the-counter

medications

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Many transit systems have initiated/enhanced their programs• Established policies• Created training programs• Implemented reporting mechanisms

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Applauded FTA for its progress and leadership All but one of NTSB’s recommendations have been

met One outstanding concern

• FTA, in concert with other US DOT modal administrations should establish a comprehensive toxicological testing requirement for a sample of fatal transit accidents to determine the role of prescription and over-the-counter medications

• FTA needs to establish a standardized method for collecting and analyzing data that provides insight into the role of prescription and over-the-counter medications on fatal accidents within the transit industry

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Develop three-year snapshot of transit industry safety record• NTD fatal accident source data• NTSB transit accident case summaries• FTA drug and alcohol audit reports

Identify and evaluate causal methods used by other industries• FMCSA• FRA• NTSB

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Elicit information from industry• Web-based questionnaire

o Policyo Education and trainingo Employee use reporting methodologyo Medical practitioner involvemento CDL physicalso Accident investigation methodologyo Post-accident testingo Causal and contributing factors identification processo Post-accident fitness for duty assessments

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In-depth interviews• Internal data collection procedure• Accident investigation procedure• Accident reports• Employee Rx/OTC records• Conduct confidential survey of employees involved in fatal

accidents Evaluate large system case studies Obtain input from advisory panel

• Transit industry professionals• Medical experts

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Recommend data collection methodologies Identify regulatory modifications Revise/update toolkit

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Complete web-based survey Make FTA aware of your approach – effective, cost

beneficial Volunteer to be on the advisory panel

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